FIRE AND SAFETY CRITICAL WORKSTREAM MEETING 19-06-2024
RICHARD This is going to be about setting the scene, deciding the objectives and the remit that we’re going to take upon ourselves. As a number of you here are from BIM4Housing, we’ve done a lot of work in BIM4Housing on fire critical assets, obviously focused on the residential angle. So we’re looking to update those pieces of guidance so that it covers right across each sector. George, do you want to pick up on that?
GEORGE We’ve obviously got quite a lot of people already involved in BIM4Housing, but there’s a lot of new people because this is BIM for Asset Management, so a much wider remit. (shares screen). What we’ve done with BIM4Housing, when we took over about 4 years ago, was changed it from BIM being about 3D modelling, which was largely the perceived view of what BIM was, to being about information management, improved information management. We looked at things across the board because information is never just within one particular phase of a project. So what e started doing was looking at how we could use information more effectively to, for example, improve the quality of information that goes through from development into construction.
So, what can development people do to make it easier for the construction teams, and the same with operations, when stuff gets handed over how can we make it so that information that’s received by the operations team is more useable. And this is the structure that we’re using within BIM In Asset Management as well. We’ve got working groups that are permanent workstreams are task and finish exercises. So, the task and finish, a particular task to do and let’s spend maybe 3 or 4 sessions working on it, come up with an answer and that then gets published. What we did with the data group, we looked at standardising information requirements and also producing data templates that could capture that information.
With the process groups we were looking at classification. For example, there’s been a lot of work done in terms of assigning things like Uniclass, but we want to make sure that we’re putting the right classifications in for asset management, which is a different perspective. Fire safety is by far and away the most active that we’ve been involved with and I’ll share some of the examples of that with you in a moment, but that’s been very successful. And in fact we’ve been feeding that back in to the Department, they’re quite keen to see the latest updates that we’ve been doing. So, any contribution that this group would have would actually have some benefit because it goes back on to the Department, which I think you all understand that it’s not the politicians, it’s actually the civil servants that are acting on these things.
We also had a group looking at sustainability and we helped to establish something called Zero which is focused on design and construction. And what I’d like to do is look at doing something for sustainability on that side of things for carbon in operations. And from Monday, we’ve had a volunteer from Turner & Townsend who’s going to lead that activity for us in BIM In Asset Management. And also digital records. So the way in which we go about this, what we find is that we’ve got in the community a lot of experience, but people work in silos. So, the approach that we take, which I think is unique, is that we bring people together, either on Teams or in person, and they can be talking to people who are possibly their competitors. But, they can also talk to their clients sitting around a table and they can also talk to people in their supply chain.
So therefore, it’s probably a unique opportunity for people to share experiences. For example, why are you actually doing a fire door inspection if you’re not doing it fully? If you’re not actually doing a deep dive and possibly taking architraves off to understand how that goes into the wall, what’s the point of having a fire door inspection? Also, potentially, what’s the point of having a fire door inspection if you’ve not checked the penetration seals? Sharon from Avesta has been coaching me in the last couple of years…not to call it fire stopping. For the record, I’m using the right terminology now. So, what we’ve done is we pulled together the groups and also we led the Golden Thread Initiative from an asset and survey information perspective.
There, for example, you’ve got a group of manufacturers all sitting around the table together and also we’ve got here a group of designers, again, all talking about things that aren’t specifically project related. And then in the far end there you’ve got the operations teams. The point about this, which I think Paul and Stephen who are on at the moment, they would say that what the Teams meetings allow us to do is to have that cross-filtering, cross-pollination, of ideas, and also the opportunity to question things without worrying that you’re going to upset a client by asking them a challenging question. Why are you actually asking me to do this? It may sound a crazy thing, but that’s the way that we’re going to get improvement. So, that’s what I’m hoping to try and achieve with BIM In Asset Management.
What we also try and do is look at things from a point of view of giving real examples, again, this group can help with this. For example, this is an example where a fire breaks out in a kitchen and what measures are in place to prevent the smoke from spreading. It might be the compartmentation that brings me to the point that I’ve been educated with over the last 2 or 3 years and that’s that the fire doors may be absolutely perfect, but unless the wall and the dampers are also performing properly, what’s the point? And when they maybe get overwhelmed you need the smoke control system and you need to detection system. So, I think it’s a matter of us looking at things as fire specialists and help us understand how the building is working as a system and then how systems need to work together.
We came up with a way of asking these questions that could really satisfy what the Regulator was looking for. The first thing was what risks does the asset itself mitigate. We’ve done it for 12 asset types, but the questions are common across them: What does it mitigate? What do people do to an asset to stop it from working? What information do we actually need about the asset to ensure that it performs as required? What do we need to know in terms of installation, specification, maintenance? What level of competency is needed? And how should any changes be recorded? And we actually produce publications to that effect. This is what Richard was just referring to earlier. We’ve had one revision on these already when they were first created in 2021, but the point about it is that what we’re doing here is trying to get a common understanding of, for example, you’ve got a fire door set, but what are the component parts?
And also, what are the risks? What do people do to them? What about the materials that could be effected? But then, what information do we need about specification, construction? And if we can come up with some standardisation on these things it’s going to make it a lot easier for us to maybe make sure that things are done to a standard, but also make them auditable. And then these are the asset types. We've got there fire doors, smoke vents, we’ve got cavity barriers, fire alarms and detection systems, dry risers and wet risers, emergency lighting, signage, sprinklers, dampers, fire dampers. Dry lining, smoke dampers and fire penetration seals. So, I think that’s a really rich set of raw information that we now want to work on. And then we also have been looking at things that break the golden thread.
One of them is how do you make sure that the right product is installed? That’s not just for new build, that’s in 10 years-time. Then, how do we ensure that the M&E services are actually designed at the right time so that we don’t end up with builder’s work holes being in the wrong place. I noticed yesterday that NG Bailey apparently are now moving directly to work for clients without going through main contractors, so that’s quite an interesting change, if anybody knows anything about that it would be good to know. How do you make sure that the asset information or the asset is consistent through the life of an asset? Which could be 30, 40, 50 years, so when it gets replaced, how do you make sure that that’s done. And also, as far as the building safety is concerned, the safety case reports, to make sure that that gets constantly updated.
We’ve had over a hundred people involved in that. This was the session we did at Digital Construction Week a couple of weeks ago where we’ve actually been through and reviewed things and that’s now feeding back in to the process. So that information is constantly being updated.
RICHARD We had a big meeting on Monday for our BIMinAM monthly forum which includes anyone and everyone actually. We’ve already got 3 workstreams, the first meeting of one of them is I think tomorrow. One looking at the business case, one looking at the digital record and one looking at interoperability. They’re all meeting over the next week or so. We’ve also set up 3, or possibly 4, new working groups. There’s existing buildings, new build, PFI and a side-focus group on soft landings which could be of interest to some of you here. If anybody is interested in any of those put your name in the chat. We’ve prepared a questionnaire. If you’d all like to go on the chat and click on that link and input your answers.
GEORGE If I could just explain. One of the things we wanted to understand is in your experience the buildings that you actually have or are working on, have they had an adequate Regulation 38 pack at handover? The next one, obviously the purpose of Regulation 38 is that you’ve got the information. The next question obviously is, is it being kept up-to-date? So, if you’re doing fire door inspections or work actually on the project you should be given access to the fire emergency file, how many of them are actually being kept up-to-date? The third one is how familiar are you with the relatively new British standard 8644 (which is commonly known as FIREie)? Do you understand the difference between the Principal Contractor CDM and a Principal Contractor Building Safety Act?
Do you know which of your buildings fall under the new fire safety regulations? Here is a slightly more interesting one, if, for example, in a hospital a treatment room with a sink and all of that sort fo stuff and the changes, maybe, to ventilation, if that is being done do you have to appoint principal designer and principal contractor? These are questions that we asked on Monday as well, so if there is any overlap with people that were on that I apologise, but it’s a worthwhile thing. If you replace a fire critical asset what level of change management do you have to go through? Do you have to go through the same change management process that you would for construction? I’m talking about during the FM stage.
If you’ve got a fire door inspection, who’s actually responsible for determining which doors need to be inspected? Replacing a smoke damper after 10 years, do you have to check the original performance specification? Do you also need the product and spec that was actually installed and its test evidence? Do you need to know what wall it’s going into?
RICHARD It’s possibly worth having a quick chat on a couple of those because we’ve got some quite diverse answers. Jiss, throw up a question where there is a lot of yeses and a lot of nos.
GEORGE That’s interesting that 25%…my understanding is that Regulation 38 has been a legal requirement for about 20 years. Paul, this is one of your areas of interest.
PAUL BRAY Every industry that I’ve worked in, when I was in the fire service we used to get building regulation consultations and requests that the Regulation 38 pack was provided. When I was working with the last housing provider and even now, the people I work with have rarely heard of it and hardly ever ask for it, they don’t know what to expect as a template. So, I’ve outlined what should be included in a template, we had a recent update to the Regulation 38 requirements and guidance on that, but generally they don’t where to apply it. It applies to any building where the fire safety order applies, so blocks of flats with communal areas, any building open to the public generally that applies to.
So I think there is a lack of knowledge, first of all, that it’s required, there’s a lack of knowledge of what’s required within the Regulation 38 pack. There is some great detail in Approved Document B that tells you what you should expect to see in that. So there’s that, but also I think contractors, designers etc, they’re not aware that they should provide it, or they don’t make it high on their priority to provide it afterwards. They’re happy to complete the build, perhaps, and then the Regulation 38 pack is an afterthought if the client requests it. That’s my experience and I’ve probably seen one or two pack sin my whole time of doing fire safety and I’ve been doing it a long time.
KAREN BYARD I've managed estates and fire safety in the NHS for too many years and I would say from my perspective I say at the outset I want my pack handing over. Because otherwise, I do think the contractors generally know they should be handing it over, but won’t offer it unless they ask for it. So I tell them from the outset you won't be getting paid if I don't get it because otherwise if they've left site I won't see it at all. And then I'm trying to manage a building not knowing actually what's been installed.
GEORGE And what’s the impact of that from your perspective? Because clearly it’s a significant thing.
KAREN BYARD I have to send my estate staff round to try and find where things are installed, what’s installed. Things like emergency lights, if we’ve got a key switch test system we’ve got to find out which key switch operates which lights because they just don’t get handed over. And it makes the first months of operation really difficult. It’s why I made the decision correctly quite a few years ago that I was telling people from the outset, if you don’t hand it over you won’t be getting paid. Because then there was no shock at the end of it when they were saying oh, we haven’t got it, we’ll get it repaired and send it, and then I never saw it. So, they were told from the outset to get it prepared. But I appreciate that you’ve got people who don’t know to expect it and then they’re going to really struggle to get it, once people have left site.
RICHARD CLARK It’s coming from the opposite end of experience from Karen. i used to be a Regulator for a fire service and the amount of buildings which we saw, I mean the word adequate here is the key thing. Occasionally we saw people with a whole tumbler unit full of O&M files which wasn’t adequate in the sense that I remember going to a school and the deputy head teacher was in charge of fire & safety and they had no change of understanding what was needed to run the school…other than to go through all of those files. So I think the idea of an adequate Regulation 38 pack really should be what you need to do to manage and run your building, as Karen mentioned. And it’s not really very good if you have to employ somebody extra to work that out for you. It will be interesting to see what effect the new regulations have because it should be the client who has to sign something to say that they’ve accepted the information and that it was adequate. And i think the ability for a client to be actually able to understand whether it’s adequate or not is questionable as well in the future.
GEORGE I absolutely agree with Richard and part of the goal that this group could help with is start to define more clearly what adequate really means. Because in many cases what i’ve seen is that there might be a fire strategy document, which is maybe 60-70 pages, that is written in such a way that is understandable by a fire engineer, perhaps, but not necessarily understandable by an FM. And the same with drawings, the number of times that I’ve seen drawings that are really quite complex and an architect has been trained for many years to be able to read those drawings and pick up from those what type of wall it is, or what type of doors have been fitted. And then they’ve got to cross-reference those against schedules.
What we’re finding is there’s much simpler ways of doing that, but somebody has got to do it. But you only do it once, so if you can do that type of thing it means that right the way down the line when other people are being asked to look at things, that’s the work that needs to be done. I think we need a mechanism whereby, in BIM4Housing we went out to 10 housing associations and councils to ask what their Regulation 38 checklists were and they varied substantially. Because of that, i think it makes it very difficult for supply chains to have the clarity of what they get. So, what Karen is doing there is really critical and that’s making it very clear to people what it is that they’ve got to deliver against.
It’s not adequate to basically say just read the regulations and make sure that you’ve complied with that, because it’s too high level. The determination of what level of detail, for example, would you, in your Regulation 38 pack, include door closers? Now, they’re an important part of the functioning of a fire door, and the same with iron mongery, but often it doesn’t get included, it’s in another schedule that if you know your way around designs and schedules and drawings and BIM models you might be able to get that information. But for people that are actually operating the building, what we’d like to do is give them much more clarity.
RICHARD OK, let’s look at another question, question 7. If you replace a fire critical asset with a different model and manufacturer does that have to go through the same change process as is defined by the Regulator for construction? Just over half of you say yes, it does need to go through the same change process. Another significant number say you don’t know and one person says no.
KAREN BYARD It’s my understanding from a building that we’re going through with at the moment, if we replace a fire critical asset with the same model and manufacturer we don’t have to go through the Regulator. But if we replace it with a different model and manufacturer we do have to go through the Regulator.
STEPHEN GORE I’m not entirely familiar of the process with the Regulator, but my thought process would be yes. if it’s a safety critical product and you’re changing it from what was originally specified and what was selected, then that needs to be considered as a change and it needs to be reviewed to make sure it’s appropriate. But we deal with the other end rather than the construction end, that would be my opinion on it.
ALASTAIR BROCKETT From my understanding of the golden thread that the Building Safety Regulator’s involvement with a building doesn’t end with post-occupation. There is provision for conquinial??? 36mins 8secs visits and inspections by the Building Safety Regulator during the life of the building. And if they notice that an asset has been changed in comparison to the original specification of the building, then there could be some awkward questions being asked at some point in the next visit.
I’m not saying that you couldn’t do it, but to avoid any repercussions then to my understanding of the Building Safety Act and its requirements to the golden thread etc, you should notify what has been done. Because from the previous conversations with people who don’t have the full SP on what is in the building, then perhaps the Building Safety Regulator may provide some form of guidance, rather than someone doing their best, with the best intentions going ahead and replacing the asset and then discovering that the next BSR inspection they’ve dropped the ball.
MARTIN OATES Just to add to that, in our specialist field of life safety smoke extract products and systems, very often most of the assets for a system are individual assets but they work together to have an overall performing system. So, of course, if you change any asset it could well change the cause and effect of the entire extract system, so from our perspective any change to an component within a system, you’ve got to ensure that that’ system is still operational in accordance with the cause and effect. So absolutely, it’s not just about component changes, it’s about component changes within the overall system.
PAUL OAKLEY There’s a lot of the functions made within the discussions about the type of buildings and they type of changes that are going on. So, whilst I was at BRE in my office we had fire door inspections come round and put a load of stickers all over these doors saying they must be kept shut, so basically separators from the corridor. And then I actually pointed out there was a massive piece of wall missing between us and the corridor and actually the fire doors were doing absolutely nothing because actually it was now redesigned as an open space. So actually replacing that fire critical asset in that location would make no difference because actually it was an open plan office. So that’s my comment on those, that basically the question actually needs a bit more detail.
STEWART PARKER I think the chap a couple of posts back there mentioned the system and going on what we said there, quite often when we look at fire dampers in walls and we talk about the penetration seals etc, it can all get let down over something as simple as a data cable being brought in. And then you have a penetration through the compartment wall, so, it has to operate as a system. More often that not we see a lot more understanding of fire doors and how they should and shouldn’t, and when we come in the maintenance programme seems to be a lot better than it would be for the fire dampers.
Because we have guys coming in, they test the fire damper quite literally just to see if it functions, and they’re unaware of if it’s the correct damper in the correct wall pack. They’re not even understanding fire strategies. So, where we see one component completely lets everything down and I think that’s where it all needs to come together. Because we see it in everything, we see the latest and greatest tests with some fire products where we have to crush sleeves etc, I see a lot of crush sleeves going through the vertical walls where you can operate on plastic and it crushes. Then I see this same item being used in a riser, a plastic crush sleeve in a riser that can have the drip effect, so it’s throughout the building, If we really looked at a building critically, you’d probably close about 99% of them.
It’s really that bad out there at the moment, and you bring it to the forefront, and Regulation 38 and all of the documents that these guys are only just beginning to try to understand. The problem is with that is that once they’ve got their pack and present it, they’re not really sure what’s in the pack, let alone what’s actually the physical side of it onsite. So, as a system, I think that’s the most important word today will be system, it has to work otherwise it’s flawed. It’s like an MOT on a motor vehicle.
KAREN BYARD We’re going through this process at the moment, obviously I look after a large hospital and we’ve been told we have to go through the building safety process for changing doors and the pest compartmentation. Now, that’s by somebody who is supposed to be qualified to advise us on the building safety procedures. if I’ve got to go through that every time that I replace a fire door we will not be able to maintain our hospital. Because at the moment it’s taking between 22 and 30 weeks to get something through. If somebody has rammed a door off with a tug I’ve got to replace the door because it’s safer to replace the door, but we’re being told now that we’ve got to go through for approval which is just mad.
GEORGE Karen, that’s very much what we’re trying to do with this group and the rest of the BIM In Asset Management group. The reason for that is that over the last 3 or 4 years I’ve spoken to hundreds of subject matter experts on fire doors. And if you ask them what their interpretation of the law is and what’s got to be done you’ll get several different interpretations. And these are not people that are not qualified or not experienced, they’re very experienced, but they’re only experienced based on their experience, if that makes sense. So, what we’ve got to do is provide a means by which people can talk…you can ask in a community environment what about this, how should we do this?
RICHARD George, why don’t you segue smoothly into answering the question, why BIMinAM? Why are we here? Because that follows quite nicely with what you’re saying now.
GEORGE (shares screen). Obviously we understand that we need to create structured digital information and the reasons for that are to try and make sure things are properly checkable and auditable. I’m going to give you an example of an audit that we’ve been involved with over this last few months. But obviously there is a range of different things, there’s the Building Safety Act, there’s the Fire Safety Act. There’s also the Defective Premises Act and there is new legislation on ESG as well. People like Karen are inundated with requirements for compliance and it’s not at all easy.
There’s then the threats of delays, as Karen was saying, at the different stages, but I think it’ quite telling, one of the reasons for BIM In Asset Management is that there is a huge amount of investment gone in over the years into the design and construction process in terms of providing classifications, standardisation, processors, software tools to make all of that easy. But the majority of the life of the building, there is much less work gone in, much less investment gone in, from the industry. So therefore software companies, like ours, we’re not getting a lot of guidance from people as to how to make that information interoperable, so we’re having to get on and do it. But the point is that that’s the area that’s probably the greatest need because it’s the bit that’s often assumed just to be…
I’ve heard it said caretakers, the examples that people tend to use in the construction industry, they say well, what FMs about is changing light bulbs. And that irritates me hugely because they’re just not appreciating why it’s important to do this. So we need to make sure that during those later stages that we’ve got the information.The starting point, as Karen was saying earlier, is the Regulation 38. And in principle, what obviously people are now legally required to do, arguably they should have always have done it, is to design in line with building regs. And also select products that satisfy the specifications are record what was installed and also record when things have been changed.
And all to often people say it will be in the BIM model, or it will be in the O&M, or because it’s been through Building Control, we assume that all of the Regulation 38 stuff would have been checked. And, of course, that isn’t the duty now of Building Control, it hasn’t been for many years. So, that\s what we’re trying to address. I’ve heard it said that data is the new oil and certainly we’re getting a hell of a lot of data. But I’ve actually checked and the person that actually came up with that was a British mathematician and what he actually said was something quite different. And that is that oil, if it’s unrefined, can’t really be used, so what we need to do is understand what information that people need, why do they need it, what happens if they don’t have it. And, as far as clients are concerned, also do they understand the value that people are delivering.
And that comes to something that Paul Oakley was just talking about earlier which is the purposes to which things are being done. So, If i give you an example, this is work that we did 4 or 5 years ago with a big housing association on a new project. We produced a set of asset lists that they said their FM team said that they needed to satisfy their requirements under the building safety. And what we actually found was that there was no mention of cavity barriers in there, no mention of penetration seals, or even fire dampers. And that then went into a bigger piece of work that we did with the Housing Association Charitable Trust and this is now the standard that, to some extent, is being used for lots of housing associations. And again, it’s fairly incomplete.
And we’re finding that the way that people are communicating on these sorts of things is probably on LinkedIn. This is one that I saw last week where somebody was doing a test of a riser system and the valve failed and ended up with flooding, but they were able to sort things out. So these sorts of conversations are going on on LinkedIn, but they’re not being captured. So what we’re trying to do in BIM In Asset Management is provide an environment where some of those experiences can be gathered. And, as was said earlier, there is now a legal requirement for clients to understand and verify and state that they understand that they’ve received the information that they need to operate the building. And also there is now a legal requirement for the construction team to actually deliver all of that information.
So what we’ve done is looked at Regulation 38 and identified the things that actually are mentioned in it. And the challenge is here that you’ve got some things there that are asset type and some that are systems. And therefore, for example, the verification of whether you’ve got all of the information that you need for that smoke control system, that needs to be broken out, otherwise you can’t really check to see that you’ve got it. It might be that you’ve got a document that covers it. So, what we’re trying to do here is look at how we can get information in a way that is auditable. so for example, you might have a data sheet for fire doors, but the way that they are describing fire rating is quite different. And people have said Ai will sort all of that out, but actually do you really want to rely on something that is trying to read something that is just described as a colour. We need some more standardisation on that.
And then finally, I’ll show you an example that we’ve been working on with a housing association. This is what they received on this particular project, basically a link to a website with PDF documents. That’s the project, when we actually opened up a couple of the documents we found that actually they’re unusable. It’s only because of the way in that was saved was somebody had zoomed out so that it would fit properly. But all of the fire stopping information, you can’t read it because you don’t know what the tags are. And when we actually raised that with the employer’s agent that’s responsible for actually delivering this, they said, well, we don’t look at things, we don’t read them. Our responsibility is just to make sure that the file has been provided. I don’t know what you think about that, I was shocked.
And what we then did was went through and identified what was missing. So you see there is a lot of greens on there because those were the things that were early Building Control level. But then when we then drilled into some more detail, this is identifying what was missing. And when we get further down- that was the Regulation 38 situation. So, because we’re trying to do this in a more methodical way of saying we can actually say that we need product literature for that particular type of product, has it been delivered? Also, it may be that you’ve got a drawing and some schedules, but then how do you then relate those things together? So, this can be quite complex to look at door schedules, for example, which architects will be able to manage that very easily, that’s what they do. But you’d need to be, if you are an FM would you have the time of the ability, if that information has been provided, because often it hasn’t.
And then if we can then use BIM to pull this together so that we can actually see both the specification of the door and also where it is and what documentation is needed against it. So, in this case, maybe an AOV or something like that, you’ve then got the ability to overlay those things so you can actually see them all in context. So, that’s the sort of thing that we need to make sure we’re actually delivering against. And finally, this is another example of that where the information is then brought together. So, you’ve got a model and you can see where the fire compartments, the 60 or the 120 minute fire compartments, but also see the assets that are protecting it. So I think that’s a way of managing that from an auditable point of view.
So what I’m saying is that if we can channel the experience of this group to say what information actually is useful and what do we need. Then, we’ve got the opportunity as a collective to feed back up to supply chains and say this is the requirements, without people then adding cost because you’re asking them for things that are unreasonable. Any thoughts on that?
RICHARD Is that a worthwhile aim? Is that what we should be doing? Is it worth your time?
BEN EVANS Actually it’s quite timely because I’m in an IPA working group which is PFI-centric we’ve got a fourth session tomorrow afternoon, on fire safety. We’re looking at scoping asset condition and maintenance of fire safety in PFI buildings across all asset classes. We have found it quite hard to get going and we have industry experts as well inputting into the sessions. But we’re still trying to, as we know it’s quite a confusing subject, particularly with the new regulations as well, as to how they all knit together (or not). Just extending on to what Karen was saying about the fire doors at Leeds Hospital. NHS Estates have brought out new HYM guidance, or replacement guidance, on fire risk assessments and they have actually brought fire door inspections to the fore.
It's quite a lengthy document, we haven’t gone through it yet, but there’s that kind of conflict with Reg 38 in terms of fire risk assessments using the ALARP principle (As Low As Reasonably Practical). Linguistically, does that chime with Regulation 38 in the specific legal requirements? So it’s all of those industry documentation guidance, does it always knit together? i don’t think it does currently, but it may do in the future.
CLIFF On the earlier topic about Regulation 38, I’ve been in the industry for about 40 years and my father for about 70 years and neither of us had heard of Regulation 38. He’s an architect and now a clerk of works,I’m an information manager, and never heard of it. So, good that it’s being brought to the surface. He’s been a lead architect on shopping centres and airports and things, but also housing as well, he’s now a clerk of works for social housing companies in London, never heard of it before.
GEORGE Regulation 38 isn’t just about housing, is it, Paul?
PAUL BRAY No, it’s not, it’s, it applies to any building where a fire safety order applies. So it will be offices, shops, anything where you have to carry out a fire risk assessment, basically. And that’s the bit that people seem to miss.
GEORGE It is extraordinary, I think.
RICHARD While we’re talking about not really understanding or knowing about things, FIREie, George, you put the question on the poll about FIREie and how familiar people were with that. The vast majority of respondents on this meeting had less than 50% knowledge.
GEORGE I’m not surprised, but it is now a British Standard, so I believe people are supposed to be complying with it. Paul Oakley is leading our interoperability group within BIM In Asset Management. Paul, could you give us a quick explanation of what FIREie is?
PAUL OAKLEY (shares screen). BS8644-1 in 2022, digital management of the fire safety information, set out the requirements of an information exchange identified as FIREie. They took on the COBie schema (Construction Operations Building information exchange) and basically rebranded it and changed things under the headings of FIREie as a way of exchanging information. But they missed out the basics that COBie has software that can write it and other software that can read it. So, for an information exchange there’s a schema, but you need solutions that can both write it and read it. And it’s unlikely that you’re going to get any software that’s going to hold the information that they’ve identified within FIREie and put it out that way.
Myself and a series of other information management people put out this to Bimplus which was basically an article that went though a lot of the issues with it. Now, the principles of what they’re trying to establish is good, because they’re trying to basically standardise the data relating to fire, but the way they’ve gone about it is a very bad implementation of it. And within the standards, those who understand the standards, there is normative and informative parts. The normatives are you shall comply with this. So, the way some of the FIREie was put across was that it is a shell, but then within some guidance and other things that they put out afterwards they retracted that and said it’s reference information about how you could go about doing it. Which obviously leaves a big issue for industry. So, you’ve got certain people saying you need to provide FIREie, but actually FIREie doesn’t work itself.
I was at BRE and worked with Active Plan defining the Templator solution that we tried to use with CPA for Lexicon. This is a template where I’ve gone through taking each of the properties identified within FIREie, so FIREie sets out all of these different sets of properties and put them in groups. Now again, some of the issues with…certain things are fine because certain things are aimed at space heating for mechanical. Some of them are associated with actual spaces, but a lot of the things are very generic so there is no identified asset types that the properties can be associated with. And then other ones which are more…There’s a protection method which relates to options of pipe, collar, concrete, or resistance finishes.
So there’s enumerated values that could be associated with stuff, or egress which is going to be associated with things like doors. But the way they’ve grouped these, they haven’t said that this information should be associated with doors, this needs to be associated with ceilings or electrical elements or things like this. So, out of the article that was put in they’re supposed to have gone back, looked at all of these requirements and redelivered it. This was August 22 when we raised all of these issues. Nothing has been published, we know the people who are involved have moved on in their jobs and moved to other places and that. I’ve tried to query with BSI but at the moment they’re not aware of what is happening on this space. So, it’s an area that really needs a lot of clarification to resolve.
RICHARD So, are you saying that FIREie is now compulsory to follow…
PAUL OAKLEY It was identified as a British Standard in normative clauses.
RICHARD But you’re saying it’s not fit for purpose.
PAUL OAKLEY Correct.
GEORGE I think if you interrogate a number of the British Standards they’re not brilliant. There’s hundreds of them. The point is from this, what can we do to take advantage of that process of having things that are machine-readable and auditable. The whole point abotu this for the community is so that we can make it easier for manufacturers of products to, for example, provide the information that they need to provide about the products that are being installed. And also for fabricators and also contractors to do that as well. So, this is something that is available if we want to do it.
Paul’s interoperability group, which Newman from Mighty is also involved in, he’s the head of strategic asset management for Mighty. It may well be that these attributes here are very useful from a design perspective, but we don’t need them for asset management. But, we might need different information for asset management. So, this information is, if you can tell Paul what information you actually need to know about a cavity barrier or a smoke damper, then it may well be that that could get fed in.
PAUL OAKLEY We’re also going through the list of attributes that they’ve defined with particular enumerated values and say actually this should be applied to these types of objects. What should be understood is that things like COBie, IFC and lots of other things have ways of carrying attributes and groups of attributes. So, all of the FIREie information could be provided using COBie or IFC or lots of other open data standards. So it doesn’t need another open data standard to deliver the information - that can be done using existing schemas. But clarity over what properties needs to be associated with what type of objects that is the key thing.
GEORGE Exactly, and if we can therefore make it so that the manufacturers, the fabricators, the installers, the maintainers, the operators have got a clear standardised definition of what information is required it would help enormously because it’s taking away the need for just relying on opinions.
STEWART PARKER It’s a massive ask, though, from design stage right down to installation and everyone in between to have a central focus point where you can go. The problem I see in my particular industry is that if it’s reached that point where we’ve got, for instance, we might have a 2 hour wall which is passed, we might have a 2 hour fire damper, but when they’re put together they’re not compliant: it’s the wrong damper for the wrong wall. Now, if it gets to that point of installation, what I’m seeing and i’ve done a case study over 30 years of assessing and going through National Occupational Standards qualifications,. So I’m out there in the field every day, in hospitals, in nuclear facilities and coffee shops. But what you see is if it’s getting to that point, how has it been specified? Who designed the system? It’s a huge task to get right throughout it all.
And then the last safety net that we actually have is do the installers understand? The guys at the coalface, are they qualified to make these decisions? And we’re still struggling now, 20 years ago there was qualifications (I know it’s not just about that), and now we’re still struggling. We’ve got operatives onsite who aren’t qualified to do the job and this is all passive fire, whether they’re involved in fire stopping, or ventilation, fire dampers, or whether they’re involved in fitting fire doors. We are still seeing companies not come to the table to make sure that their operatives are qualified. So asking them to understand a lot of this information needs to be taught, to be honest.
GEORGE Most definitely, we are actually trying to help with that, I’ll just show you. We’ve had a team…everybody on this, we’re all volunteers, we’re not setting this up just to have another working group or another body. I’m not aware of anybody that’s actually doing what you just described there and that’s looking across the piece. This is an example, we built on something that was developed for the NHS which is a standardised way of doing fire door inspections. We picked this up and it goes through the process and it identifies three types of fire door inspections. One is of a brand new door, another is of an existing door to understand what it is, and the third is then the ongoing fire door inspections.
STEWART PARKER I think having this in place is great. I’ve come away from a huge hospital project recently where the only reason the fire door was exposed for a fault was the fire door and the frame were perfect, and it wasn’t until you got to the header that it was attached to an MDF architrave. It was sat around the door and it wasn’t screwed in any way, the header was screwed to it. The actual architrave was used with a spit gun, so there was just a nail gun put the architrave in place. And, of course, because of the resistance on the door when you opened it the architrave come off and subsequently this door could open and close at will. And it was blowing open and closed.
And it wasn’t until the NHS consultant, at this brand spanking new hospital, looked at it and said, wow, we’ve got a problem. Now they’ve got to go around and check every single closure…because once it’s painted it’s very difficult to unearth those problems. Unless you have a full frame of the architrave etc that you can see how it’s fitted. But, more often than not, a bit of painting and decorating done after will cause problems if you don’t know what you’re looking for.
GEORGE Exactly, so the point about this is that this is something that was originally created for the NHS and they’re currently doing one for dampers and ventilation systems as well, which we’re also robbing.
STEWART PARKER Who’s doing that for the dampers and ventilation?
GEORGE It’s the National Association of Healthcare Fire Officers (NAHFO). What we’re doing, with their permission, it’s Alan Oliver that runs that for the NHS. We’ve taken it and we’ve run this through the BIM4Housing community and a lot of people have put quite a lot of effort into this. So we’ve now got this as a new publication and it’s doing exactly what Stewart was just saying there. It’s giving explicit examples and training for people on what to look for. And this is the sort of thing that we now want to broaden and do that, exactly the same way, for all of those other fire safety critical assets.
STEWART PARKER I think it’s great, I think for CPD etc and the rest of it, but what I’m seeing a lot of is guys who actually sit very short two day courses (a maximum of 16 hours) CPD. And with some of the associations in my field, there’s 4 associations that have got 4 different ideas who all run 4 different two day courses. And at the end of it, they're telling people they can go out and check these assets. You will have an onslaught of chippies checking installations and really that’s what we’ve got to be careful of because I see it in ventilation where a guy will literally let off a fire damper, reset it, that’s the job done. And it’s very similar to me putting the kettle on and turning the kettle off, I wouldn’t call myself an electrician just because I can turn a kettle on and off.
But these guys are giving out certificates and the certificates that they give you, they look all glamorous, then they will walk up to a facilities manager or an estates manager at a hospital, present it and say we’ve tested your fire dampers, and they will walk away. Those fire dampers that I go to visit through third-party accreditation, are nowhere near compliant. They’re dangerous, they’re putting people’s lives at risk and a lot of the time you get the wrong damper in the wrong facility. I still see non-actuated dampers in hospital facilities and exactly where Karen was going, it’s a very complex decision to make if you’ve got a damper that’s been installed 20-30 years ago and if we want to replace it we can’t replace it like-for-like.
Because regulations have changed, how many times has the Building Act changed since 1984? And in 2010 the latest Building Safety Act that we go back now, Regulation11 F, the biggest thing in the Building Safety Act that’s changed for me is compliance and competence, how do we measure it? so, unless we get that right people will just have a lot more paperwork and they won’t understand it and they’ll just be tick-boxing.
KAREN BYARD Yeah, I agree. I have got my Masters degree in fire doors and I’m astounded at some of what are supposedly third-party accredited repairs that we’ve got on some of our doors. I look after more than one Trust, it’s just beyond appalling, and they’re paying through the nose for it because they’re saying that they’re third-party accredited. And the issues that I’ve identified recently, I am going to go back to the accreditation body because if that’s been done through third-party accreditation it’s not even worth paying for.
STEWART PARKER You’re right, Karen, because the problem is when we look at the third-party accreditation we have to be careful because we have the facilities that can measure and test products in-house: Bray etc, Warrington Fire and the rest of them, I get that. But when you have a third-party that comes to the table and then they come into the NHS and they present themselves as a genuine third-party, I know one third-party. But, the majority of third-party, they will come in and they’d look at your policies and procedures, they only know how to work with policies and procedures. And they’ve got totally wrong ISOs in place to come on to a site and look at a fire door or to come and look at a fire damper.
The threat isn’t policies and procedures, although it’s very important the paperwork that sits behind it, the physical threat now for me onsite is the installation. We can look what we’ve created for the past 30 years with historical problems. I thought we’d have a line in the sand with the Building Safety Act and the Building Safety Regulator coming to this point, especially after the tragedy at Grenfell. But it seems that what I feel has been created is now there is a whole new market for people to go all compliance and competency and the rest of it, but there not compliant and competent themselves. But they’re just calling themselves this as a business opportunity.
KAREN BYARD The third-party accredited body that I’ve got an issue with the company that’s supposedly doing it to that standard, is a recognised body. It’s a recognised body that you spend a fortune to get part of and you get lots of testing and checks to make sure that you’re compliant.
STEWART PARKER You need to ask them for a declaration of compliance to begin with. If they’ve got National Occupational Standard qualifications in place and if they’re time-served operatives, brilliant. But the majority of the time what you’ll find quite quickly is that I know 4 associations and unfortunately we have to work through them because one of them works through the government. The problem that you’ll see quite quickly is that…I can go and sit a two day course next week and not be industry at all, and I can walk away from it and come into your hospital and I can set your fire dampers on and off and put your people at risk. And the same with hygiene, especially with grease extract cleans and the rest of it. Someone can walk in to a hospital or into a shopping mall and say that they’re the expert to do that and it’s putting so many people at risk.
ALASTAIR BROCKETT I’ve been listening to the last few conversations and whilst this is probably not going to solve things overnight I’d like to think that in the coming future it’s going to try and ease the concern about competency, training etc. The competency steering group, they’ve got their 12 working groups looking to provide competency matrixes for the relevant stakeholders within the passive fire protection industry. And hopefully this will then start narrowing down and defining what is required of these people. With regards to, in my own field, passive fire protection, working group 12 of the competency steering group is working on fire stop installers, or passive fire protection installers.
And whilst that is a kind of general competency matrix, the ASFP have a couple of working groups that are looking to narrow this down to a list of, yes, whilst these are the general requirements, the ASFP are trying to define specifics so that a person doing the installation of fire stop will be expected to have this level of knowledge, this level of understanding, this level of experience and this level of behaviour. There is also a working group for passive fire protection designers and again, the ASFP are trying to narrow this down in terms of this is what is expected of these people. So, with regards to these competency steering groups, working group 12 which is for passive fire protection, the plan for that is to have it actually as a British Standard but early 2025. Other groups are expected to follow with regard to this. It covers things like fire engineers, architects, installers, inspectors. So, there is a working group for each one.
STEWART PARKER The ASFP failed to recognise the National Occupational Standard qualification, it’s already there for fire stopping. That’s robust, that’s a government requirement for the minimal technical competence that we need to perform a task onsite. so, moving away from the government legislation, ASFP being another association with paying members who are sat actually on working group 12 really doesn’t give me confidence that we’re going to get the outcome that we require. E-learning seems to be all the rage at the moment, we have to look at the guys at the coalface doing the job.
GEORGE What we’ve now got, we’ve got the workstreams and what I’m hearing here we’ve got a number of different things that we’ve got going on. We’ve got the business case workstream which is I think the driver for a lot of this stuff because we can actually say this is the reason we actually need this to be done in a more rigorous way. I think that’s what you’re saying, Stuart. We’ve also got the digital record workstream which is looking at what type of evidence is needed and how the best way of delivering that for people at the coalface. And the third one is the one that Paul’s running which is the technical one, the interoperability one.
And that may not seem so relevant to you, but the easier that it can be when somebody is doing something for their purpose, for that to update the other systems becomes really quite important. So if we can use that to define what our information requirements are, particularly from the asset management end of fire critical assets, then what are the fire critical assets that we actually want information on? I’m sure that collectively we could pull that together. So, would you mind putting in the chat whether you’re interested in any of those workstreams that Richard was talking about earlier. Or you can do that on the website.
RICHARD On our website it gives you details of all of the working groups, all of the workstreams, when their next meeting is and to request an invitation for a meeting. Or just bung us an email.
GEORGE To the people that haven’t yet spoken on this, because obviously people are coming on to learn, do you feel what we’re doing is actually worthwhile? Because we’re all volunteers, I’m a volunteer and I’m trying to fit this in around my working day, do you think that what we’re doing here is worthwhile?
FRANCIS MOORE Having somewhere where it’s all uniform and a standardised approach would be that’s your golden standard for everything. There’s so many times that we get clients come to us and they’re in need of information, but the information they find on the internet, you can find something to fit the narrative. No matter what you want to be your agreed principles you could find something on the internet to agree with that and then you can print that. We always get them handed to us and say no, no, no, this is what the internet says. So, in order for your website as such to be a hub of that kind of i information, an agreed standard information source would be fantastic.
GEORGE Thank you very much, and certainly that’s what we want to try and do. The other thing is what we’ve found on the BIM4Housing work is that people that wouldn’t normally talk to each other, or have the opportunity to talk to each other, actually become colleagues. And they can ask each other questions. So, it becomes a real community where…Stewart, for example, his frustrations, who do you talk to about that, Stewart? It’s difficult for other people who aren’t doing what you’re doing to understand it. Whereas it’s really, really important.
FRANCIS MOORE The amount of different opinions and information you get, when you speak up it gives the opportunity to be shot down so quickly very, very easy. So forcing this to happen is a fantastic idea.
GEORGE Also if we can identify based on experience. I don’t know, Holly, if you’re still there. Holly is a fire engineer and some of the examples that we really want to do is capture experiences to say, like that one I showed you earlier with a fire breaking out in a kitchen. We could do with a dozen or so, probably more, examples of scenarios that then enable you to look at system thinking.
FRANCIS MOORE Yeah, I’ve been a fire fighter for 20 years so I’ve seen systems in place that work and systems in place that definitely do not. To have that kind of information at a click would be your golden standard.
RICHARD You’ll receive an email sometime next week with the highpoint notes of this meeting and a video link should you wish to watch yourself again. We won’t be having another meeting now until September, but we will be in touch on that and other things. If you’re interested in joining any of those working groups put it in the chat. We’ll see you after the summer.
GEORGE Could you also communicate this with other people because we want this to become a movement, a wider community.So if you know people that would be interested in this then please ask them to engage with us.
CHAT
[11:40 am] Richard Clark (External)
Worth highlighting that this would only be for buildings in their scope in occupation (HRBs 18m+) - Other building control bodies may need to be consulted for other buildings
[11:49 am] Martin Oates (SE Controls UK) (Unverified)
in addition to ensuring a changed product meets the compliance and performance criteria of the original product, it must also seamlessly integrate with the cause and effect
[11:59 am] Paul Bray (Guest)
The point Karen made about having to consult with the regulator for every fire door repair is a topical issue, and may relate to the BSR not being equipped to deal with the number of consultations or requests for approval. I know of organisations that had to stop projects that were about to start, because of incorrect advice from one BSR regulator, that said contractors on the 'competent person scheme'. The result is an expensive rescheduling of contractors and revised communication to the stakeholders. The need for control over building works in HRBs (or any other building for that matter) is critical, but the process for getting critical life safety works completed, must be building manager friendly, or else it will fail to achieve what it set out to do. Not sure what the solution is though.
[12:03 pm] Richard Clark (External)
No, it's every building
[12:31 pm] Paul Bray (Guest)
Sorry, If this is true, it is different from my interpretation of Regulation 38 which refers to 'relevant buildings' and a relevant building being where the fire order applies or will apply. (38.1 and 38.3.b) I would be interested to know where I have misinterpreted this. Here is a link to where I obtained my understanding - https://www.legislation.gov.uk/uksi/2010/2214/regulation/38
[12:33 pm] Richard Clark (External)
Well, with the updates to the FSO applicability in a domestic setting encompassing residential buildings of more than two dwellings, it means many more buildings are now in this scope.
[12:34 pm] Paul Bray (Guest)
But it is not every building...
[12:35 pm] Richard Clark (External)
Ok, not single dwellings on their own.
[12:03 pm] Brockett, Alastair (Unverified)
its previous incarnation was Reg 16
[12:10 pm] Paul Oakley (External)
[12:20 pm] Trigg, Karen (Unverified)
Hi where can I get a copy of this please?
[12:20 pm] James Lucas (External)
Can I get a copy of that and the dampers?
[12:22 pm] Richard Clark (External)
For doors, the converse can also be true; adequate doors could be failed leading to large costs for responsible persons
Hear, hear.
[12:24 pm] Paul Oakley (External)
BS 8644-1:2022 Digital management of fire safety information. Design, construction, handover, asset management and emergency response. Code of practice.
Standard that refers to FIREie
[12:28 pm] Alan Brown (External)
The only way you can be sure if remediation works can be undertaken on a fire door is if the manufacturer has these remediation works in there field of application , no third party can give assurances as they have not tested the product
[12:28 pm] Alan Brown (External)
Look at Forza Doors data sheets
[12:32 pm] James Lucas (External)
I believe its worthwhile, I'm mid 20's and listening to all of industry experts is great!
[12:34 pm] Richard Clark (External)
For reference, this is from the Fire Safety Act 2021: "Article 6 arifies the extent to which the FSO applies.
Where a building contains two or more sets of domestic premises, the things to which this order applies include—
(a) the building’s structure and external walls and any common parts;
(b) all doors between the domestic premises and common parts (so far as not falling within sub-paragraph (a))."